20 Melbourne University Law Review [Vol 41(2):Adv B Canada 1 Laws Enacted In mid-2014, the Canadian federal Parliament followed in the UK’s footsteps by passing the Strengthening Canadian Citizenship Act, SC 2014, c 22, which introduced a number of new disloyalty-based citizenship revocation grounds into the Citizenship Act, RSC 1985, c C-29 (‘Canadian Citizenship Act’).93 Prior to this, Canadian citizenship was, by global standards, a very secure status: naturalised citizens could have their citizenship revoked by ministerial discretion on grounds of fraud or where there was a concealment of material circumstances, but Canadians could not otherwise lose their citizenship against their will.94 The Strengthening Canadian Citizenship Act expanded the grounds for revocation considerably to include three new circumstances. First, it created a ministerial power to revoke a person’s citizenship where an individual is convicted of any of a series of prescribed offences under Canadian law relating to national security.95 Secondly, it made revocation possible where a citizen had been convicted in a foreign jurisdiction of an offence committed outside Canada that, had it been committed in Canada, would qualify as a ‘terrorism offence’ under s 2 of the Criminal Code, RSC 1985, c C-46.96 Finally, the Minister was granted the power to revoke citizenship where he or she had reasonable grounds to believe that the person concerned, while holding Canadian citizenship, served in the armed forces of a country or ‘as a member of an organized armed group’ where ‘that country or group was engaged in an armed conflict with Canada’.97 Before exercising this final power, the Minister was required to obtain a judicial declaration that the person engaged in the activity in question.98 A degree of protection against statelessness was also provided for: the three new grounds for citizenship revocation did not authorise revocation that ‘conflict[ed] with 93 Pillai and Williams (n 9) 540. 94 Ibid 529. 95 Strengthening Canadian Citizenship Act, SC 2014, c 22, s 8, amending Canadian Citizenship Act (n 8), the latter as repealed by An Act to Amend the Citizenship Act and to Make Consequential Amendments to Another Act, SC 2017, c 14, s 3(1) (‘Canadian Citizenship Amendment Act’). 96 Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10(2)(b), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 3(1). 97 Strengthening Canadian Citizenship Act (n 95) s 8, amending Canadian Citizenship Act (n 8) s 10.1(2), the latter as repealed by Canadian Citizenship Amendment Act (n 95) s 4(2). 98 Ibid. Advance Copy